Donate
Resources
Pay your bill Compliance Domestic Violence Financial Assistance

Corporate Compliance

Corporate Compliance ensures that the Family Counseling Center operates in accordance with applicable laws, regulations, and internal policies and procedures. The Corporate Compliance Department enhances the mission and vision of TFCC to provide quality supports, care and services by promoting integrity, legal and ethical behavior, and reducing the likelihood of fraud, waste and abuse.

Compliance Officer

The Family Counseling Center is required to designate the responsibility of operations for the Corporate Compliance Program.

Sarah Quist is the Corporate Compliance Director and serves at the Corporate Compliance and HIPAA Privacy Officer.

Questions, compliance-concerns, or HIPAA Privacy concerns may be directed to her at:

Sarah Quist, Corporate Compliance Director
11-21 Broadway
Gloversville, NY 12078
Phone: (518) 725-4310 x109
E-mail: squist@thefamilycounselingcenter.org

Corporate Compliance Program Overview

The Family Counseling Center is required to have an effective compliance program. The Corporate Compliance Program is operated by a Compliance Plan which outlines actions of the program to prevent, detect, and fix concerns going forward.

What are Examples of Compliance Concerns?

While not inclusive, below are some examples of compliance concerns that should be reported include:

  • Billing for services that were not actually rendered;
  • Charging more than once for the same services;
  • Billing for medically unnecessary services;
  • Falsifying records used to bill or retain payments;
  • Not timely reporting and returning an overpayment;
  • Inappropriately disclosing or using confidential information regarding employees or patients/clients
    supported;
  • Violating applicable laws, regulations, or internal policies and procedures;
  • Being unlicensed and performing services that only a licensed professional may render; and/or
  • Accepting a bribe or kickback from a vendor or contractor.

If there is a question of whether a particular activity should be reported, please reach out to a supervisor or the Corporate Compliance Department.

Prevention Measures

Training and Education – The Corporate Compliance Program includes training and education for new hires, annual refreshers, and, when necessary whether as remedial training or initiative.

Policies, Procedures and Standards of Conduct – The policies, procedures and Standards of Conduct for the Compliance Department are accessible on the Intranet for staff on TFCC website or asking the Compliance Department for a copy.

Reporting Mechanisms – The Family Counseling Center has established and implemented a number of ways in which compliance concerns can be confidentially reported. They are described more fully below.

Who Should Compliance Concerns be Reported to?

Compliance Concerns related may be confidentially reported:

Background Checks – Criminal background checks are performed on persons following an offer of employment, but prior to starting work. In addition, checks are performed on staff, vendors/contractors, Board members and volunteers against various exclusion lists published by Federal and State agencies. These lists identify, among other things, individuals and entities who have been convicted of health care fraud.

Disciplinary Standards – The Family Counseling Center has established disciplinary standards, and implemented procedures for the enforcement of such standards, to address potential compliance violations and encourage good-faith participation in the Corporate Compliance Program.

Detection Measures

Billing Safeguards – The Family Counseling Center utilizes software designed to assist in the proper documentation of billable services as well as processes for monitoring and review.

Auditing and Monitoring – The Corporate Compliance Department performs audits and other reviews across the organization to prevent, detect, and correct concerns. These reviews are determined based a variety of factors including risk assessments, and the work plans of the United States Office of Inspector General and New York State Office of the Medicaid Inspector General.

Conflicts of Interest – The Family Counseling Center has an established policy that contains standards and procedures for identifying and addressing conflicts of interest.

Responding to Compliance Concerns – The Family Counseling Center has established and implemented procedures and systems for promptly responding to compliance concerns, including issues reported to the Corporate Compliance Department or identified in the course of an internal or external audit.

Other pertinent Corporate Compliance Information

What is Your Role in the Compliance Program?

All persons associated with the Family Counseling Center are responsible for conducting themselves in accordance with applicable laws, regulations, and internal policies and procedures. This includes employees, interns, volunteers, contractors, consultants, and vendors– all of whom are expected to
understand and comply with the Corporate Compliance Program, including reporting suspected compliance concerns, as well as cooperating with, and participating in, compliance-related reviews, audits, and investigations.

What is Fraud, Waste, and Abuse?

It is the policy of the Family Counseling Center to comply with all applicable Federal and State laws pertaining to fraud, waste and abuse in health care programs. Various laws define these terms differently; however, they generally are described as:

Fraud – An intentional deception or misrepresentation of information made by a person with the knowledge that the deception results in unauthorized benefit to themselves or anther person.

Waste – The mismanagement of resources, including incurring unnecessary costs because of inefficient
or ineffective practices or systems.

Abuse – Having practices that are inconsistent with generally accepted business or medical practices.

Non-Retaliation Policy

Under the Whistleblower Protections and Non-retaliation policy, retaliation and/or intimidation against anyone who reports a concern in good faith is prohibited. Reported concerns and claims of retaliation will be reviewed and, if required, investigated. Any person who has engaged in acts of retaliation and/or intimidation will be subject to appropriate disciplinary action, which may include termination of employment or other relationship with the agency.

Deficit Reduction Act of 2005

The Family Counseling Center is committed to compliance with the Deficit Reduction Act of 2005, and has adopted a policy that summarizes the federal and state laws and administrative remedies for preventing and detecting fraud, waste and abuse, and those that provide whistleblower protections. All contractors, consultants, and vendors are expected to abide by these policies while performing services for, or on behalf of, or supplying products to the agency.

HIPAA- Healthcare Insurance Portability Accountability Act

Corporate Compliance also ensures the confidentiality, privacy, and availability of confidential information, protected health information, electronic protected health information, private personal information, and patient information as defined under applicable Federal and State laws, rules and regulations, including, but not limited to, HIPAA, New York Mental Hygiene Law, New York Public Health Law, and New York Security Breach and Notification Act.